Employers Not Obligated to Provide Stress Free Workplace

December 26, 2001 - Neither Washington State law nor the Americans Disability Act (ADA) require employers to replace supervisors who inflict emotional stress, according to the Washington Supreme Court.

In Snyders v Medical Service Corp, the court ruled that the medical company did not have to provide case worker Michelle Snyders with a new supervisor as an accommodation.

Case History

Snyders’ lawyers charged that her 300lb, six feet supervisor Celestine Hall used her size to intimidate those around her — so effectively that several employees resigned, citing Hall as the reason.

According to Snyders, Hall threatened her with disciplinary action if she asked for a raise, and accused her of insubordination when she objected to working on a Saturday without pay.

Snyders met with Hall’s supervisor and told him she had a post-traumatic stress disorder. She asked to report directly to him or to be transferred to another department. Her request was declined.

She resigned and sued her former employer in state court for violations of state laws, claiming:

  • constructive discharge,
  • failure to make a reasonable accommodation for her mental disability,
  • outrage, and
  • negligent infliction of emotional distress

Medical Service Corp won the suit, and Snyders appealed.

Appeals Court

The court noted that, according to case law, the duty to accommodate an employee’s disability only arises once the employee makes the employer aware of the disability — which Snyders, citing post traumatic stress disorder, only did when she asked to be transferred to another supervisor. The company had no reason to accommodate her.

Further, the court noted that employers do not have a duty to provide a stress-free workplace, and that the tort of negligent infliction of emotional distress does not exist in the employment context.

– Camilla Klein         editors@plansponsor.com